Labor Code §6401.9(f)

SB 553 Training: Who, When, and How to Prove It

Initial + annual training with interactive Q&A. Who needs it, when, and the 11-column CSV that proves it.

Teams train but fail on the record. Nine of ten SB 553 training citations come from missing fields, not missed sessions. Trainer name blank, date vague, no proof employees could ask questions.

§6401.9(f) requires interactive initial and annual training, plus extra training when a new hazard appears or the plan changes. You must show who was trained, when, on what, by whom, and that employees could ask questions. Subilu does this with 5 minute mobile sessions, a Q and A portal, and an 11 column CSV that maps one row per employee per session, from session to attestation.

Who needs training and when

If an employee can be exposed to violence at work, they are in scope, including supervisors.

WhoWhenTrigger
New hireBefore placement or first shiftHire date
All covered staffAt least annually12 months from last completion
Affected staffNew hazard identifiedHazard evaluation for that site
Affected staffWVPP changes materiallyPlan alters controls or reporting

The last two rows are where programs drift. Annual does not cover a new late night closing or a moved cash station. Those need extra training before staff resume that work. Subilu marks sessions by type, initial, annual, hazard update, or plan change, so you can prove you trained on the update. Attendance is per person, not per site.

What interactive means: Q and A portal

Interactive does not mean long. It means employees can ask questions and get answers from someone who knows the plan.

In Subilu this is three things. A Q and A flag on every session, includedQa as Yes or No, which you must set before adding the first attendee. The session then locks to protect the record. Access to the WVPP and how to get a copy. And an open Q and A portal after the session, so follow up questions do not disappear.

Five minute mobile is how this fits real schedules. Staff complete on phones between shifts and ask a question if needed. Completion is timestamped. Six topics from SB553_REQUIRED_TOPICS anchor every session: Workplace Violence Prevention Plan, Reporting Without Fear of Reprisal, Site Specific Hazards, Corrective Measures, Seeking Assistance, and Violent Incident Log.

Without Q and A, it is not interactive
A video with no way to ask is not interactive under §6401.9(f). Subilu records includedQa for every session. If it is blank, the session cannot accept attendees.

The 11 column CSV that proves it: session to attestation

Export gives you training-compliance.csv, one row per attendee per session. Eleven columns connect the session to the person who attests.

#ColumnSourceWhy it matters
1Session DatesessionDateWhen training occurred
2Trainer NametrainerNameWho delivered it
3Trainer QualificationstrainerQualificationsThat trainer was qualified
4Training Typeinitial, annual, hazard update, plan changeWhich duty it satisfies
5Topics Coveredvia SB553_REQUIRED_TOPICSWhat was taught
6Content SummarycontentSummaryEnough detail to show site relevance
7Q and A IncludedincludedQa as Yes or NoProof of interactive element
8Employee NameemployeeNameWho was trained
9Job TitlejobTitleRole at that time
10Attestation Methodmanager recorded or self attestedHow attendance was confirmed
11Attestation DateattestedAt as YYYY MM DDWhen employee confirmed

Manager recorded means a supervisor logged attendance. Self attested means the employee confirmed through a magic link with expiry. The column shows which applies so you can answer a challenge without digging through email. The CSV is separate from the WVPP and the incident log. Three files, not one ZIP.

Run one test before your next batch. Add a session, set trainer and topics, mark Q and A, add one attendee, then download the CSV. If any of the 11 columns is empty, fix that field before you train the group.

See training with Q and A →

Not legal advice. Source: Labor Code §6401.9(f) and DIR training guidance. Pair with 7 Required Log Fields.

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